Melville Fuller
Melville Weston Fuller (February 11, 1833 – July 4, 1910) was an American politician, attorney, and jurist who served as the eighth chief justice of the United States from 1888 until his death in 1910. Staunch conservatism marked his tenure on the Supreme Court, exhibited by his tendency to support unfettered free enterprise and to oppose broad federal power. He wrote major opinions on the federal income tax, the Commerce Clause, and citizenship law, and he took part in important decisions about racial segregation and the liberty of contract. Those rulings often faced criticism in the decades during and after Fuller's tenure, and many were later overruled or abrogated. The legal academy has generally viewed Fuller negatively, although a revisionist minority has taken a more favorable view of his jurisprudence.
"Justice Fuller" redirects here. For other uses, see Justice Fuller (disambiguation).
Melville Fuller
July 4, 1910 (aged 77)
Sorrento, Maine, U.S.
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Calista Reynolds(m. 1858; died 1864)
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Mary Coolbaugh(m. 1866; died 1904)
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Born in Augusta, Maine, Fuller established a legal practice in Chicago after graduating from Bowdoin College. A Democrat, he became involved in politics, campaigning for Stephen A. Douglas in the 1860 presidential election. During the Civil War, he served a single term in the Illinois House of Representatives, where he opposed the policies of President Abraham Lincoln. Fuller became a prominent attorney in Chicago and was a delegate to several Democratic national conventions. He declined three separate appointments offered by President Grover Cleveland before accepting the nomination to succeed Morrison Waite as chief justice. Despite some objections to his political past, Fuller won Senate confirmation in 1888. He served as chief justice until his death in 1910, gaining a reputation for collegiality and able administration.
Fuller's jurisprudence was conservative, focusing strongly on states' rights, limited federal power, and economic liberty. His majority opinion in Pollock v. Farmers' Loan & Trust Co. (1895) ruled a federal income tax to be unconstitutional; the Sixteenth Amendment later superseded the decision. Fuller's opinion in United States v. E. C. Knight Co. (1895) narrowly interpreted Congress's authority under the Commerce Clause, limiting the reach of the Sherman Act and making government prosecution of antitrust cases more difficult. In Lochner v. New York (1905), Fuller agreed with the majority that the Constitution forbade states from enforcing wage-and-hour restrictions on businesses, contending that the Due Process Clause prevents government infringement on one's liberty to control one's property and business affairs. Fuller joined the majority in the now-reviled case of Plessy v. Ferguson (1896), in which the Court articulated the doctrine of separate but equal and upheld Jim Crow laws. He argued in the Insular Cases that residents of the territories are entitled to constitutional rights, but he dissented when, in United States v. Wong Kim Ark (1898), the majority ruled in favor of birthright citizenship.
Many of Fuller's decisions did not stand the test of time. His views on economic liberty were squarely rejected by the Court during the New Deal era, and the Plessy opinion was unanimously reversed in Brown v. Board of Education (1954). Fuller's historical reputation has been generally unfavorable, with many scholars arguing that he was overly deferential to corporations and the wealthy. While a resurgence of conservative legal thought has brought Fuller new defenders, an increase in racial awareness has also led to new scrutiny of his vote in Plessy. In 2021, Kennebec County commissioners voted unanimously to remove a statue of Fuller from public land with the aim of dissociating the county from racial segregation.
Early life[edit]
Melville Weston Fuller was born on February 11, 1833, in Augusta, Maine, the second son of Frederick Augustus Fuller and his wife, Catherine Martin (née Weston).[1]: 903 His maternal grandfather, Nathan Weston, served on the Supreme Court of Maine, and his paternal grandfather was a probate judge.[2]: 4 His father practiced law in Augusta.[3]: 1471–1472 Three months after Fuller was born, his mother sued successfully for divorce on grounds of adultery; she and her children moved into Judge Weston's home.[3]: 1472 In 1849, the sixteen-year-old Fuller enrolled at Bowdoin College, from which he graduated Phi Beta Kappa in 1853.[4]: 120 He studied law in an uncle's office before spending six months at Harvard Law School.[5]: 339 While he did not receive a degree from Harvard, his attendance made him the first chief justice to have received formal academic legal training.[5]: 339 Fuller was admitted to the Maine bar in 1855 and clerked for another uncle in Bangor.[6]: 199 Later that year, he moved back to Augusta to become the editor of The Age, Maine's primary Democratic newspaper, in partnership with another uncle.[7]: 30 Fuller was elected to Augusta's common council in March 1856, serving as the council's president and as the city solicitor.[3]: 1472
Death[edit]
While at his summer home in Sorrento, Maine, Fuller died on July 4, 1910, of a heart attack.[15]: 224 Upon hearing of his death, President Taft praised Fuller as "a great judge"; Theodore Roosevelt said "I admired the Chief Justice as a fearless and upright judge, and I was exceedingly attached to him personally."[13] James E. Freeman, who later served as the Episcopal Bishop of Washington, conducted the funeral service.[7]: 329 Fuller was buried at Graceland Cemetery in Chicago.[14]: 371
